The new telco DFV standard protects customers. Who protects the workers?

Australia’s Telecommunications DFSV Standard 2025 is a landmark for victim-survivors. But it has a blind spot — and it’s the people answering the phones.

On 1 July 2025, Australia’s first enforceable telecommunications standard for domestic, family and sexual violence (DFSV) came into force. The Telecommunications (Domestic, Family and Sexual Violence Consumer Protections) Industry Standard 2025, made by the ACMA under Part 6 of the Telecommunications Act 1997, replaced a decade of voluntary guidelines with binding obligations. Full compliance for large providers was required by 1 January 2026, and small providers by 1 April 2026.

It is, without question, a significant step forward for consumers experiencing violence. Telcos must now urgently reverse disconnections where there’s a safety risk, provide specialist DFV-trained staff, offer new accounts not linked to a perpetrator, and critically — must not require evidence of abuse or force a victim-survivor to engage with their abuser for account changes or debt resolution.

This is good regulation. I support it.

I’m not writing this from the sidelines. RWTS was an initial signatory to the telecommunications industry DFV pledge, and we’ve been working on DFV-aware practices internally for three years — training our team, building processes, and thinking seriously about what it means for a technology services provider to handle these situations well.

This issue came into sharp focus for me yesterday during a discussion with the Internet Association of Australia’s Public Policy Advisory Panel, where we were examining ACMA enforcement priorities for the new standard. As the conversation progressed, I kept coming back to a question that nobody in the room had a good answer for.

We’ve spent years building protections for the people on one side of the phone call. But there is a gap in this standard that nobody appears to be talking about — and I believe it represents a real and quantifiable risk to the people on the other side.

The numbers we can’t ignore

In April 2023, the Australian Child Maltreatment Study (ACMS)— Australia’s first nationally representative prevalence study — was published in the Medical Journal of Australia. It surveyed 8,503 Australians aged 16+ and found that 62.2% of Australians experienced at least one form of maltreatment during childhood.

Not a small minority. Not a marginal statistic. The majority.

The breakdown is confronting:

  • 39.6% were exposed to domestic violence as children
  • 32.0% experienced physical abuse
  • 30.9% experienced emotional abuse
  • 28.5% experienced sexual abuse
  • 39.4% experienced multiple types of maltreatment

Separately, the ABS 2021–22 Personal Safety Survey confirmed that 1 in 7 Australians (14.1%) experienced childhood physical and/or sexual abuse — the narrower but equally authoritative measure covering abuse by adults before age 15.

Among those with maltreatment histories, 48% met criteria for at least one mental disorder, compared with 21.6% of those without. A 2024 University of Sydney analysis attributed up to 40% of Australia’s mental health burden to childhood maltreatment.

The workforce the standard forgot

The DFSV Standard mandates two tiers of training: general DFV awareness for all personnel (Section 21), and specialised training for customer-facing staff (Section 22) covering the nature of DFV, intersectionality, and how to identify and engage with affected customers.

There is exactly one reference to worker safety in the entire standard — a requirement that training cover “recognising and prioritising the safety of personnel engaging with perpetrators.”

What’s missing is everything else:

  • No mandatory employee counselling or debriefing tied to DFV disclosure handling
  • No clinical supervision or peer support structures
  • No workload management to limit DFV case exposure per worker
  • No re-traumatisation risk framework for staff
  • No requirement for Employee Assistance Program access specifically linked to this work

The standard requires “trauma-informed” policies and training — but this framing is exclusively consumer-directed. The same principle is not extended to the workers delivering the support.

When the person answering the call is also a survivor

Here’s the maths that should concern every telco executive and every regulator.

If 62% of Australians experienced childhood maltreatment, and 39.6% specifically witnessed domestic violence as children, then in any team of 10 frontline telco staff, statistically 6 carry some form of childhood trauma, and 4 witnessed the very type of violence they are now required to respond to professionally.

This isn’t speculation. Research on DFV advocates (Slattery & Goodman, 2009) found that 55% were themselves survivors of past abuse, and that survivor status was the only individual factorthat significantly predicted secondary traumatic stress. Without organisational support structures, every DFV disclosure a telco worker receives becomes a potential re-traumatisation event.

The neurodivergent dimension

There is a compounding factor that makes this even more acute for the technology and telecommunications sector specifically.

Two WHO-commissioned Lancet meta-analyses have established that children with disabilities experience 2–4 times the rate of abuse compared to non-disabled peers. Condition-specific research deepens this: a 2023 meta-analysis found 44% of autistic individuals reported victimisation, while research on ADHD found 45.6% had experienced maltreatment (OR 2.39). Adults with dyslexia reported childhood physical abuse at five times the rate of those without.

The tech and telco workforce has disproportionate neurodivergent representation. Australia’s TechDiversity Foundation “Tech Reflects” 2024–25 study found 12.4% of participants self-identified as neurodivergent — likely an undercount, given that international surveys show up to 50% self-identification when asked directly, with 57% having never disclosed at work. Simon Baron-Cohen’s Cambridge research on 450,000+ participants found STEM workers score significantly higher on measures of autistic traits.

The intersection is clear: a workforce with elevated neurodivergent representation, where neurodivergent individuals face 2–4× the baseline abuse risk, is now required to handle DFV disclosures — without any mandated psychological safety framework.

The research that doesn’t exist

Here is perhaps the most concerning finding from my research into this topic:

No peer-reviewed research exists — in Australia or internationally — specifically studying vicarious or secondary trauma among telecommunications workers handling DFV cases.

The same gap applies to energy, water, and banking workers, despite all these sectors now having DFV-specific regulatory obligations. The vicarious trauma literature overwhelmingly focuses on clinical, social work, and emergency service settings.

What does exist points clearly to the risk. The Law Society of NSW explicitly identifies call centre staff as a population vulnerable to vicarious trauma. Australian call centre workers take 10–15 days of sick leave annually compared to a national average of 6–7 days. Safe Work Australia reports that psychological injury claims have increased 80% over five years.

A 2023 study published in PMC warned that even trauma-informed practice training itself can re-traumatise attendeeswhen it includes detailed survivor accounts.

The WHS obligation already exists — it just hasn’t been connected

Safe Work Australia’s Model Code of Practice: Managing Psychosocial Hazards at Work (2022) creates obligations under WHS legislation that arguably already cover the psychosocial risks for telco workers handling DFV disclosures. Exposure to traumatic content, emotionally demanding work, and inadequate support are all recognised psychosocial hazards.

But no regulator — not the ACMA, not Safe Work Australia, not any state WHS authority — has explicitly connected these obligations to the new reality of mandatory DFV disclosure handling in Australia’s telco workforce.

What I’m calling for

To be clear: I am not calling for the standard to be weakened. I am calling for it to be completed.

But I want to be equally clear about where the responsibility for completing it should sit. This is not a problem for small telcos to solve on their own.

The government created this obligation. The ACMA enforces it. The standard applies to every carrier and carriage service provider in the country — from Telstra down to a regional ISP with a handful of staff. The compliance burden is already significant, particularly for smaller providers who don’t have dedicated DFV teams, in-house psychologists, or the scale to absorb the cost of specialist training and support infrastructure.

You cannot mandate that an entire industry’s workforce absorb trauma disclosures as a regulatory obligation and then leave it to individual businesses — many of them small — to figure out the psychological safety implications on their own. That is a transfer of public health risk onto private employers without the resources to manage it. And the data tells us this isn’t a niche risk — it’s a majority-of-your-workforce risk.

The Australian Government committed $22.4 million to fund ACMS Wave 2, which will for the first time include disability and neurodivergence breakdowns. That investment signals the government understands this is a public health issue. The workforce side of the equation deserves the same recognition.

Specifically, I’m calling on the Australian Government to:

  1. Fund the development of a workforce psychological safety framework for the DFSV Standard — not as an unfunded add-on for providers to build themselves, but as a government-resourced initiative developed with DFV experts, WHS specialists, and the telco industry. This should include model policies for counselling access, debriefing protocols, workload management, and re-traumatisation risk assessment that providers of any size can adopt.
  2. Commission and fund research through the NHMRC or ARC into vicarious and secondary trauma among non-clinical workers in telco, energy, banking and other sectors now handling DFV disclosures as a regulatory obligation. This is a gap in the evidence base that the government created by extending DFV obligations to these workforces — the government should fund closing it.
  3. Direct Safe Work Australia to issue explicit guidanceconnecting existing psychosocial hazard obligations under WHS legislation to DFV disclosure handling in regulated industries. The legal framework already exists — it just hasn’t been connected to this new class of occupational exposure.
  4. Establish a funded support program — potentially through the Telco Together Foundation or a similar vehicle — that provides subsidised access to trauma-informed supervision, EAP services, and peer support networks for smaller providers who cannot build these capabilities in-house. The energy sector’s approach to hardship programs offers a model: industry-wide infrastructure funded collectively, not left to individual small businesses.
  5. Require the ACMS Wave 2 study to include occupational exposure analysis — specifically examining whether workers in DFV-disclosure-handling roles experience different psychological outcomes, and whether neurodivergent workers in these roles face compounded risk.

This is a public health issue that the government has, rightly, chosen to address through regulation. But regulation without resourcing is just risk transfer. If we’re serious about protecting victim-survivors — and we should be — we need to be equally serious about not creating a new class of psychological casualties in the workforce tasked with delivering that protection.

An invitation

I would welcome engagement from researchers, regulators, unions, DFV advocacy organisations, and telco operators on this issue. If research exists that I’ve missed, I want to know about it. If organisations are already addressing this gap internally, I want to hear how. And if you’re in government and this has crossed your desk — I’d genuinely welcome the conversation about how to get this right.

The standard asks telco workers to hold space for some of the most traumatic disclosures a person can make. The least the government can do is resource the industry to hold space for them in return.


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